Farm-Scape, Episode 2157

Canadian livestock producers are being encouraged to familiarize themselves with existing requirements for transporting livestock under the Health of Animals Act and to make themselves aware of changes that are being proposed for those rules.

Part 12 of the Health of Animals Regulation addresses the transportation of all species of livestock into Canada, out of Canada, and within Canada by any mode of transport, air, land or water. When introduced in 1975 the intent was to prohibit poor practices and reduce the risk of injury, suffering or death of animals in transit.

“The regulations that were written 30 years ago, and still apply today, are difficult to interpret in terms of the situations that we face today,” states Dr. Gord Duncan, the Canadian Food Inspection Agency’s (CFIA) senior staff veterinarian responsible for humane transportation of animals.

In December 2005 the CFIA made public, through its internet web site, a document which outlines the key reasons for considering change and the types of change being considered and it invites stakeholders to provide their input. As part of what is being described as a pre-consultation, stakeholders comments are being accepted until at least the end of July.

“There’s a need to reflect new practices, new expectations and new information – especially new information arising from science and from the types of transport practices that have evolved over the last 30 years,” Dr. Doonan explains. “The second reason is the need for clarification by providing definitions, reducing vague terminology and using accepted standards that are widely recognized to help to make the expectations more clear. And thirdly, to facilitate consistent enforcement across Canada.”

Eight Key Areas Targeted for Possible Modification.

“What we’re considering doing is to make changes that are needed to reflect what happens today and the knowledge that we have today and current expectations. It’s not to make a lot of changes to what industry is already doing,” Dr. Doonan says. “In a sense the process began over five years ago. This is a result of cumulative needs for specific changes and, as these needs have been brought to my attention, I have kept them in a file and the file has grown to the point now where we believe the time may have come to make an actual amendment.”

“Normally we would be doing consultations after publication in Canada Gazette Part 1,” he explains. “Because of the large number of amendments that we’re considering, we're involving the stakeholders much earlier in the process.”

“Stakeholders will have an influence, first of all, as to whether we indeed proceed with an amendment and, if we do proceed, they can have an influence earlier in the process. The hope is that, if we do proceed and we publish a change in Canada Gazette Part 1 that the formal comment period that follows that would be less contentious. There’d be more acceptance of the changes because they would reflect what the stakeholders had already told us.”

“Actually,” he points out, “the current draft already reflects a lot of stakeholder comments that we’ve received.”

Need For Change Recognized but Details Raise Questions

There appears to be a widespread recognition of the need to modernize the regulation but there are questions being raised about some of the changes being suggested.

Dr. Byrnne Rothwell a retired veterinarian and appointed director with the Saskatchewan Stock Growers Association, suggests, “The regulations haven’t been updated for some time so it’s timely to have them updated to make sure they’re fair and synchronized, to a degree, with our trading partners if that’s possible. In terms of humane treatment it's time that they were reviewed.”

However he says, “From a stock grower’s point of view, we have some questions.”

Pork Producers Also Preparing Response

Manitoba Pork Council has also drafted a response to the proposed changes, complete with recommendations and supporting documentation. That document will be forwarded to the Canadian Pork Council within the next couple of weeks for presentation to CFIA.

“What we’re requesting from CFIA is that they take a scientific approach,” says Manitoba Pork Council swine program specialist Miles Beaudin. “Also what we're looking to do is have other industries endorse it as well.”

Key concerns expressed so far tend to revolve around such variables as the duration of transport, stocking densities and requirements for providing stock with rest, feed and water during transport.

Dr. Rothwell notes, for example, a proposed reduction in confinement times for ruminant animals from 48 hours down to 36 hours in combination with a recommendation to increase feed, water and rest times from five to eight hours would stretch a trip from Moose Jaw to Kitchener from 44 to 52 hours.

He stresses, “We’re not in a position to say, as stock growers, whether or not this change should or should not take place. We would just like to see the documentation and the research which would bare out that this has a welfare benefit.”

As an example he says, “Our trade in calves to Ontario and the US, if we have to run these calves through a feed, water and rest station, there may be an actual increase in the levels of shipping fever. We don’t know these things until further research is done.” That particular factor actually raises another red flag.

“One of our concerns is the suggested change that more prescriptive information is going to be put into regulation,” says Susan Church, the general manager of the Alberta Farm Animal Care Council (AFAC).

She explains, “We feel quite strongly that that should not happen and that the new regulation or any changes in the regulation should refer to codes of practice that the industry have developed or are developing. The codes stay current and can change and show how the industry changes and grows based on new information, new research, new trucks, new methods of transportation. The regulation is set in stone.”

She stresses, “Where there’s so many variables involved – weather, type of animal, distance, driving conditions, type of vehicle – we feel it’s very important to look back at the codes of practice.”

Dr. Rothwell agrees, “Entrenching these requirements into regulation will make them more difficult to change as new information comes to light.”

He would like to see those specific recommendations stay where they are until there is more information on whether they are or are not accurate.

Only Reasonable Well Grounded Amendments to be Considered

Dr. Doonan explains, the intent of amending the legislation is not to make a lot of changes to what industry is already doing. He notes, “We’re not saying industry is doing a bad job and they have to change. We’ve been getting pretty strong messages from some of the industry groups that we may be responding to political pressure or public pressure in the absence of a reason, and that’s not the case at all.”

“What we’re looking for is underlying rational for what the stakeholders want us to do, not just opinions but reasons for that.” He insists, “Any particular change that we would make would have to be based on a strong [scientific] rational and not just an opinion.”

Most People Want to Do What's Right

Dr. Doonan stresses, “We believe that animals are transported very well in Canada, but there's always a minority who will stop at nothing and what ever it takes to make a dollar they’ll do it. This is not a reflection of typical Canadian industry but there are individuals and companies out there who will subject animals to undue suffering during transport.”

“It’s really for that minority that regulations are required.” He is convinced, “Most people are going to do what is right as long as they know what the acceptable standards are. But in the absence of regulations people who are in business are put under pressure by competition to reduce their standards and if there is no regulatory control the end result will be low standards that would be unacceptable.”

He concludes, “Regulations actually protect the majority who want to transport animals properly yet remain competitive.”

For Farmscape.Ca, I'm Bruce Cochrane.